Center for Survivor Agency and Justice, National Consumer Law Center, and National Coerced Debt Working Group Submit Comments to CFPB on Rulemaking to Combat Coerced Debt
FOR IMMEDIATE RELEASE | Date: 03/11/2025
Washington, DC – On Friday, March 7th, the the Center for Survivor Agency and Justice (CSAJ), National Consumer Law Center (NCLC) and the National Coerced Debt Working Group (CDWG), a coalition of over 20 local, state, and national organizations, filed Comments with the Consumer Financial Protection Bureau (CFPB) in response to the CFPB’s Advanced Notice of Proposed Rulemaking on the Fair Credit Reporting Act (Regulation V); Identity Theft and Coerced Debt. This marks an important milestone, after over a decade of collective advocacy efforts, and sets the stage for transformative changes in consumer protection for survivors of domestic violence.
The comments focus on the critical issue of coerced debt and its detrimental impact on survivors of domestic violence. Coerced debt is a form of economic abuse where an abusive partner uses, exploits, and/or damages credit for their own advantage and to restrict survivors’ agency. Research shows that nearly all survivors experience some form of economic abuse (94-99%), and half report experiencing coerced debt (Adams et al., 2008).
The comments address the pervasive issue of coerced debt, highlighting the long-term financial consequences on survivors and illuminating why regulatory protections are crucial. As stated in the comments:
Coerced debt has severe negative consequences for all victims, including damaged credit scores, difficulty obtaining housing and employment, and reliance on predatory lending, trapping them in a cycle of debt and increasing their risk of violence. Rulemaking by the Consumer Financial Protection Bureau (CFPB) to address coerced debt under the Fair Credit Reporting Act (FCRA) is crucial for removing systemic barriers caused by coerced debt, offering victims of coerced debt a path to economic and physical safety.
After reviewing the existing literature, CSAJ, NCLC, and the CDWG launched the 2025 National Coerced Debt Survey to gather data to inform the comment writing process. Over a two-week period, the survey received 206 responses from 40 States and the District of Columbia. Combined, respondents served approximately 2,570 people per month in 2024, half of whom had experienced coerced debt– 8,000 – 14,640 coerced debt victims served in 2024. The survey unearthed the systemic barriers that survivors face, underscoring the need for regulatory action: “Importantly, 80% of respondents said “no one” or at most “a few” of these coerced debt victims were successful in disputing coerced debt with Credit Reporting Agencies. Ninety-nine (99%) said “no one” or “a few” successfully obtained a block on their coerced debt.”
The ANPR represents a critical step forward in the effort to protect survivors from the long-lasting financial and physical harm caused by coerced debt. The findings from the 2025 National Coerced Debt Survey reinforce the urgent need for the CFPB to enact meaningful reforms that remove systemic barriers and enable survivors to access the critical resources needed to be safe. CSAJ, NCLC, and, and the CDWG remain committed to advocating for policy changes that protect survivors of domestic violence and their economic security. We urge the CFPB to take swift action on these recommendations.
The deadline for filing comments has been extended to April 7, 2025. If you are interested in filing comments, you can do so here. Thank you for helping us mobilize around this meaningful opportunity at this critical time. If you have questions or would like any additional information please reach out.
Contact: Center for Survivor Agency & Justice, Erika Sussman (erika@csaj.org)
Citation’s and Related Resources:
- CSAJ and NCLC Petition the CFPB for FCRA Rulemaking on Coerced Debt
- National Survey on Barriers to Disputing & Blocking Coerced Debt
- Compendium on Coerced Debt (CSAJ, 2023)
- Consumer Rights Newsletter on Coerced Debt (CSAJ, 2023)
- Development of the Scale of Economic Abuse (Adams et al., 2008)
- Survivors Economic Wellbeing, Debt Burden – National Snapshot (Adams & Wee, 2019)
- Understanding Coerced Debt (Adams, Littwin)
###
The Center for Survivor Agency and Justice is a national nonprofit organization that advances economic equity for survivors of gender based violence, by building the capacity of advocates and attorneys, strengthening organizational and community responses, and fueling systems and policy change. To learn more about our work, visit https://csaj.org